On January 14, 2025, President Trump signed a proclamation entitled “Adjusting Imports of Semiconductors, Semiconductor Manufacturing Equipment, and Their Derivative Products into the United States.” The proclamation imposes a 25% tariff under Section 232 on certain advanced computing chips that meet the technical specifications detailed in Annex I of the proclamation. The measure
On December 23, 2025, the United States Trade Representative (USTR) determined that China’s policies and practices aimed at dominating the semiconductor industry are unfair and burdensome on U.S. commerce, making them actionable under Section 301 of the Trade Act of 1974. After a year-long investigation, the USTR found that China’s state-driven industrial planning, forced technology
On July 27, 2025, President Trump announced that the U.S. and European Union (“EU”) have reached a trade deal. Pursuant to the Fact Sheet released by the White House on July 28th, the U.S. will impose a 15% tariff on all EU goods, including auto parts, pharmaceuticals, and semiconductors. The Fact Sheet further stated that
On April 14, 2025, the Trump Administration issued two federal register notices scheduled to be published on April 16, 2025. The notices seek public comments following the April 1, 2025 initiation of investigations targeting imports of pharmaceuticals and semiconductors pursuant to Section 232 of the Trade Expansion Act of 1962. The Trump administration claims that imports of semiconductors and pharmaceuticals are a threat to national security.
On September 13, 2024, the U.S. Trade Representative (USTR) announced that it has finalized the modifications to the Section 301 trade actions following the completion of its four-year statutory review in May 2024. As described in a prior post, on May 22, 2024 USTR released a draft list of imported goods for which it
BIS Adds 24 New Entities and Removes One from Entity List
On December 8, 2022, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a notice in the Federal Register adding 24 entities under 26 entries and removing one entity from the Entity List. The entities are from Latvia, Pakistan, Russia, Singapore, Switzerland
On October 4, 2021, Ambassador Katherine Tai, the United States Trade Representative, addressed the state of U.S.- China trade relations and the upcoming plans for the Biden Administration to improve foreign trade policy. Since taking office in January, the Administration has spent time reviewing the trade policies put in place under the Trump Administration. There has been little movement until now as to the stance the Biden Administration would take, which created uncertainty regarding U.S. trade policy with China. Speculation grew as many questioned what would happen with the tariffs imposed on Chinese imports (under Section 301), how the administration would address the shortcomings of the “Phase 1” deal, and whether the product exclusion process would be re-instated.
The Department of Commerce’s (“Commerce”) Bureau of Industry & Security (“BIS”) recently issued requests for comment on risks to the information communications and technology (“ICT”) and semiconductor supply chains. These comments are being requested as part of the U.S. government’s broader review of supply chain vulnerabilities (see here, here, and here).
ICT
President Biden issued an “Executive Order on America’s Supply Chains” (the “EO”) on February 24, 2021, ordering 100-day and 1-year reviews of certain critical supply chains. The initial 100-day review aims to assess risks posed to the following critical supply chains: